Lord Houghton was chief of defence staff, the UK’s most senior military officer, from 2013 until 2016. He joined the House of Lords as a crossbencher on 20 November 2017.

Earlier that year, the Advisory Committee on Business Appointments (ACOBA) recommended the former chief of defence staff shouldn’t work with a particular tech start-up company.

Nevertheless, as I exclusively revealed on 25 February 2019,General Houghton was one of two individuals who controlled the firm at the date of the advice letter. The advice letter makes no reference to the fact that he was co-owner. The advice letter is of interest for another reason: it contains a non-trivial error. As I showed, the ex-chief of defence staff failed to inform ACOBA of the error.

As of 1 February 2019 the Conservative MP for Chatham and Aylesford is a “senior adviser” to The Playbook, a PR agency for sport, consumer, tech and business brands. Ms Crouch is paid £4.25k a month for “providing advice on the benefits of sport”, according to the register of MPs’ financial interests. It requires “20 hrs a month”. On 24 April 2019, meanwhile, she was appointed as an “independent” member of British racing’s Horse Welfare Board. The former minister will receive “£27k per annum plus reimbursed expenses” for “10 hrs a month”.

The first problematic link arises because The Playbook’s clients include Great British Racing Limited (GBR), the agency website shows (screen shot in Figure 1). GBR is horseracing’s “official marketing and promotional body, working with all of racing’s stakeholders”, says the GBR website. The firm is owned and controlled by the British Horseracing Authority (BHA), according to Companies House records. GBR and BHA share the same address, too (screen shot in Figure 2). The Horse Welfare Board, by happy chance, is also at BHA, as the register of MPs’ financial interests confirms.

Figure 1. Great British Racing is a client of The Playbook: The Playbook website at 10 May 2019

Figure 2. Great British Racing contact details: Great British Racing website at 10 May 2019

Ms Crouch was already working for The Playbook, therefore, when she joined the Horse Welfare Board. Thus the MP is actually non-independent given GBR is a client of the agency.

The second problematic link is via political lobbyist Hanover Communications. The Playbook is owned and controlled by Hanover Communications – whose lobbying clients include BHA, according to the latest public affairs register, 1 December 2018-28 February 2019, at the Public Relations and Communications Association (PRCA) website. While the ex-sports minister isn’t working directly for the political lobbyist, The Playbook acts for GBR, a subsidiary of BHA. Further, BHA hosts the Horse Welfare Board, two of whose eight members work for BHA.

Also, Hanover Communications and The Playbook are at the same address.

Because of Ms Crouch’s involvement, the Horse Welfare Board deserves scrutiny. The BHA press release on 18 April 2019 announcing her appointment as an “independent” member says the Horse Welfare Board “will also look at how the sport’s welfare standards are communicated and how they are perceived by the sport, the public and other audiences” (screen shot in Figure 3). It says nothing about engaging politicians and government, then. Contrast the earlier BHA press release (25 March 2019) marking Barry Johnson’s appointment as independent chair of the Horse Welfare Board: it’s explicit about the body engaging politicians and government (screen shot in Figure 4). Presumably Hanover Communications will play a role in political lobbying by the Horse Welfare Board. Regardless, there’s a need for clarity and transparency around how exactly the body will engage politicians – besides Ms Crouch! – and government.

Figure 3. Tracey Crouch MP appointed as an “independent” member of the Horse Welfare Board: British Horseracing Authority press release on 18 April 2019

Figure 4. Barry Johnson appointed as independent chair of the Horse Welfare Board: British Horseracing Authority press release on 25 March 2019

On 12 March 2019, the Advisory Committee on Business Appointments (ACOBA) published its advice letter to Ms Crouch about her role at The Playbook. There the committee stipulated: “for two years from your last day in ministerial office, you should not become personally involved in lobbying the UK government on behalf of The Playbook or its parent company [Hanover Communications] or clients”. Thus the ACOBA advice letter only reinforces the concerns about the Horse Welfare Board and its contacts with politicians and government.

At date of publication ACOBA hasn’t published its advice letter to Ms Crouch about her role at the Horse Welfare Board.

Finally, there’s something else about The Playbook: it also works for gambling company 888sport, the agency website shows. In addition, gambling is central to client GBR: one of the thirteen questions in the FAQs on the GBR website, for example, is simply “How do I bet?” Answer: “Placing a bet is simple. To help you out, why not take a look at the easy-to-follow betting content in our Guides section.” Hanover Communications, meanwhile, acts for FTSE 100 bookie Paddy Power Betfair as well as BHA (plus many other clients).

With gambling closely linked to both new other jobs, it’s strange to recall the circumstances around Ms Crouch’s resignation as sports minister on 1 November 2018. Back then she lambasted the government for delaying until October 2019 reduction of the maximum stake on fixed-odds betting terminals (FOBTs) from £100 to £2. (In fact, the stake cut on FOBTs came into effect on 1 April 2019.) Ms Crouch was widely hailed at the time for her perceived principled resignation. So why is the MP now working for both The Playbook, which promotes gambling, and the Horse Welfare Board, which sits within BHA, the organisation responsible for a sport dependent on gambling?

Mark Pritchard MP, a government trade envoy, worked for the SmartWater Foundation from 1 November 2017 until 31 March 2019, according to theregister of MPs’ financial interests. “Providing strategic advice”, the Conservative MP for the Wrekinwas paid £1 666.66 a month for “an expected commitment of 18 hours”. The SmartWater Foundation “provides not-for-profit forensic technology solutions”, says Mr Pritchard on the register. It’s unclear, though,how the Telford-based organisation could employ the local MP.

The last publicly available accounts for SmartWater Foundation Limited (registered company number: 06181622) are made up to 31 March 2018. These show the company appears to be dormant and there are no assets.

Why do I say “appears to be dormant”? Because the last accounts contain no evidence the company is doing business (“trading”). Further, there’s no evidence there the firm has any other income, either. (http://www.gov.uk/dormant-company)Thus the inference is a reasonable one.

Mr Pritchard began working for the company on 1 November 2017. So the last accounts include the first five months of the MP’s job.

Companies House records show SmartWater Foundation Limited is a private company limited by guarantee, a legal structure often used by not-for-profit organisations. Nevertheless the fact remains it’s unclear how the firm could employ Mr Pritchard, when its last accounts don’t contain any evidence of business activity, let alone any evidence of employing – and therefore paying – the Tory MP or anyone else.

The SmartWater Foundation is part of the multinational SmartWater group of companies, which includes UK-based SmartWater Technology Limited(registered company number: 02875523). For the avoidance of doubt, the SmartWater Foundation isn’t a registered charity.

When asked for comment, a member of Mr Pritchard‘s office at parliament, Daniel Pycock, answered on his behalf. Mr Pycock challenged my assertion SmartWater Foundation Limited appears to be dormant. When I gave the reasons for the inference, he didn’t reply.Separately, I requested a comment from the SmartWater Foundation via the enquiryform on the SmartWater website (http://www.smartwater.com). An immediate, automated email acknowledgement was the only response I received.